Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Denial of concessional duty rate for import of 'waste paper' used in production of 'paper' instead of 'newsprint', non-maintenance of separate books concealed from excise authorities to obtain 'end-use certificate'. Insolvency and Bankruptcy Code, 2016 proceedings - no inconsistency with determination of duty liability on past clearances. Penalties u/s 112 of Customs Act on individuals - no specific finding on their role in furnishing 'end-use' certificate, only overall managerial role considered. Confiscation u/s 111(m), not 111(d). Penalties on individuals set aside for lack of determination of their responsibility in import and filing bill of entry. Appeal disposed.
Denial of concessional duty rate for import of 'waste paper' used in production of 'paper' instead of 'newsprint', non-maintenance of separate books concealed from excise authorities to obtain 'end-use certificate'. Insolvency and Bankruptcy Code, 2016 proceedings - no inconsistency with determination of duty liability on past clearances. Penalties u/s 112 of Customs Act on individuals - no specific finding on their role in furnishing 'end-use' certificate, only overall managerial role considered. Confiscation u/s 111(m), not 111(d). Penalties on individuals set aside for lack of determination of their responsibility in import and filing bill of entry. Appeal disposed.
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